Now that you know the general cybersecurity requirements for the FTC Safeguards Rule (16 C.F.R. Part 314), let’s walk through the five essential technical controls you need to put in place.
1. Access controls and MFA
The FTC requires you to tightly control who can see your data and use your endpoint devices. Access controls ensure that employees only get into the files and systems they actually need to do their jobs. Additionally, the FTC makes MFA a mandatory security control for anyone logging into your network. Standard two-factor authentication (2FA), like combining a password with a secondary code or physical security token, counts as an adequate protection.
2. Continuous monitoring
One of the biggest hurdles for lean teams is keeping up with continuous monitoring, which the FTC requires so your organization can spot unauthorized access or unusual activity in real time. Periodic scanning just doesn’t offer the same constant visibility that the government expects. However, building out a massive in-house team with 24/7 coverage and specialized tooling is expensive. To solve this, many companies hire a managed SIEM service to handle the heavy lifting while creating the audit trail required for compliance.
3. Encryption of customer data
The FTC requires you to encrypt customer data wherever it lives or travels. This means protecting data while it travels across the internet, as well as when it’s sitting on your local computers or in the cloud. Though encryption is critical, it’s more like a final safety net than a proactive measure. If threat actors somehow bypass your other defenses and access data, encryption scrambles it into unreadable gibberish, rendering it useless.
4. Risk assessments
You must run and document written risk assessments to uncover potential security threats. This is an ongoing process, not a one-time job. Your team can start with a standard FTC Safeguards Rule risk assessment template, but you must update it whenever your business environment changes, such as changing vendors or adding a new server. The FTC wants to see that your information security program grows and adapts alongside your business.
5. Incident response planning
The FTC mandates that you have a written emergency incident response plan ready before a breach ever occurs. You can’t simply write it once and let it gather dust. Instead, you must test it to make sure it actually works. Just like your risk assessments, you’ll need to update this plan as your technology changes. It should also clearly assign roles so your legal, IT, and executive teams know exactly what to do in a crisis. This helps you respond much faster if an attack occurs.
